Polyus recognises its responsibility to respect human rights when conducting business. The Company supports the endorsement in 2011 of the UN Guiding Principles on Business and Human Rights and the rights contained in:

Universal Declaration on Human Rights;

International Covenant on Civil and Political Rights;

International Covenant on Economic, Social and Cultural Rights;

International Labour Organization’s Declaration on Fundamental Principles and Rights at Work

Voluntary Principles on Security and Human Rights

The Company recognises the rights of its employees to a safe and healthy working environment, to non-discrimination and the freedom of association and acknowledges the customs and cultures of local communities in the areas in which it operates.

All employees, directors and officers of Polyus must adhere to this Policy.

Policy

Polyus commits to conducting its operations in accordance with domestic legal requirements and internationally recognized human rights. In particular, it shall uphold the following principles:

Treat all employees, staff and suppliers fairly and without discrimination and in a manner that respects their dignity;

Respect the freedom of association and freedom of expression of all employees;

Respect the rights, cultures and customs of the communities in the areas in which Polyus operates, including indigenous communities;

Ensure that stakeholder engagement is regarded as a core component of the Company’s corporate policies;

Operate a zero-tolerance policy on bribery;

Ensure security personnel comply with all legal requirements, in particular with regard to the use of force.

Delivery

Polyus ensures compliance of all of its corporate policies and procedures with the principles of this Policy.

All Company employees, including all new hires, are required to take an introductory training on the Company’s Human rights policy.

In all process related to stakeholder engagement, including the engagement with public authorities, the Company shall comply with the requirements of the Policy.

Polyus will ensure that a confidential grievance mechanism is available through which human rights complaints can be reported and addressed.

Where human rights have been adversely affected, the Company will work to provide appropriate remedies.

Monitoring and Reporting

The Company agrees to regularly (at least annually) assess the compliance of its activities with the principles of this Policy.

The Company reserves the right to assess employee compliance with the requirements of the Policy. In cases of non-compliance, the Company has the right to apply corrective measures.

Monitoring of compliance shall also be carried out as part of the assessment of the sustainability strategic objectives achievement. Information on the implementation of the Policy is included in the Company’s Annual Report.